Chemical inventory, safety data sheet management, secondary container labeling and employee training — the four things an inspector asks for in the first thirty minutes, usually in that order.
The written list was built once and never maintained. Maintenance buys a new solvent, production trials a new adhesive, and neither reaches the list. An inspector walks the shelf and compares.
SDSs must be readily accessible to employees on every shift. Binders in a locked office, files on a computer nobody can access at 2am, and sheets for discontinued products all fail that test.
Spray bottles, transfer containers and parts washers filled from a drum need labels with product identifier and hazard information. This is the most visible finding on any walkthrough.
Employees must be trained on the specific hazards in their work area and on how to read labels and SDSs. A generic annual video does not meet it.
The standard requires a written hazard communication program describing how you handle inventory, labeling, SDSs and training. Many companies do the practice and never wrote the program.
Hazards from non-routine tasks and information sharing with contractors working in your areas are explicit requirements that are almost universally undocumented.
We walk the site and build the chemical inventory from what is physically present — production, maintenance, lab, janitorial and the drums nobody has claimed in years. Then we reconcile against purchasing so the list stays current after we leave.
From there: SDS collection and an access method that works on every shift, a secondary labeling system, the written program, and area-specific training tied to the chemicals employees actually handle.
Yes, provided access is immediate and unimpeded on every shift, with a backup for power or network failure. In practice, sites with a single office computer and no night-shift access do not meet the standard.
For every hazardous chemical present. Consumer products used in the same manner and duration as ordinary consumer use are treated differently, but that exemption is narrower than most people assume.
Specific to the hazards in the employee work area. A welder and an office worker do not need the same training, and giving everyone the same session usually means the welder was undertrained.
Both parties are required to exchange hazard information. You need to know what they brought, and they need to know what your areas contain.
Four to eight weeks for a typical mid-sized manufacturer, with the inventory walk being the labor-intensive part.
Twenty minutes to scope a HazCom rebuild and tell you what a document request would turn up.
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